Is allulose a sugar? What the FDA and a federal court say
Is allulose a sugar? Chemically yes, on the Nutrition Facts panel no. Here's why that split now decides million-dollar “zero sugar” labeling lawsuits.
Short answer: Is allulose a sugar? Chemically, yes — it is a monosaccharide with the same molecular formula as fructose, and the FDA has said so directly in federal court. But since 2019 the FDA has also let manufacturers leave allulose out of the “Total Sugars” line on the Nutrition Facts panel, because your body barely metabolises it. Both statements are true at once, and that contradiction is exactly what the current wave of “0g sugar” lawsuits is fighting over.
What allulose actually is
Allulose (also written D-allulose or D-psicose) is a rare sugar. It occurs naturally in small amounts in figs, raisins, wheat, maple syrup and molasses, and it is produced commercially by converting fructose with enzymes.
Structurally it is a monosaccharide — a single sugar unit — with the molecular formula C₆H₁₂O₆, identical to fructose and glucose. It is an epimer of fructose, meaning the atoms are arranged slightly differently around one carbon. That small difference is why it tastes like sugar (research puts it around 70% of the sweetness of sucrose) but passes through the body largely unused.
Roughly 70–80% of ingested allulose is absorbed and then excreted in urine, essentially untouched. It contributes about 0.4 calories per gram versus 4 for table sugar, and it does not meaningfully raise blood glucose or insulin.
Why the Nutrition Facts panel can say 0 g
In April 2019, the FDA published a notice and guidance telling manufacturers they may exclude allulose from the “Total Sugars” and “Added Sugars” declarations on the Nutrition Facts panel. Calories from allulose still have to be counted, and it still has to appear in the ingredient list.
The reasoning was metabolic, not chemical. The sugar lines on the panel exist to tell you about calories and blood-sugar impact. Allulose delivers almost none of either, so listing it alongside sucrose would mislead people in the opposite direction.
The practical result is that a bar sweetened entirely with allulose can legitimately print “Total Sugars 0g” in the black-and-white box on the back — and that is not a loophole, it is the FDA's stated position. You can read it yourself in the Federal Register notice.
The split: the back panel vs. the front of the box
Here is where it gets interesting, and where the lawsuits live. The Nutrition Facts panel and front-of-pack marketing are governed by different rules.
A statement like “0g Sugar” splashed across a wrapper is a nutrient content claim, governed by 21 C.F.R. § 101.13. Subsection (i)(3) says a food may not carry a claim about the amount of a nutrient if the claim is “false or misleading in any respect.” Separately, 21 U.S.C. § 343(a)(1) makes any food misbranded if its labeling is false or misleading.
And the definition of “sugars” those rules point to — in § 101.9(c)(6)(ii) — is chemical, not metabolic: “the sum of all free mono- and disaccharides.” Allulose is a free monosaccharide.
| Where the claim appears | Governing rule | Can it say 0 g sugar? |
|---|---|---|
| Nutrition Facts panel, Total Sugars | FDA 2019 allulose guidance | Yes — allulose may be excluded |
| Nutrition Facts panel, Calories | 21 C.F.R. § 101.9 | No — calories must be counted |
| Ingredient list | 21 C.F.R. § 101.4 | No — allulose must be listed |
| Front-of-pack “0g Sugar” | 21 C.F.R. § 101.13(i)(3) | Contested — this is what is being litigated |
What the Seventh Circuit and the FDA said in 2026
In July 2026 the Seventh Circuit decided Franco v. Chobani, LLC, and it moved the question from theoretical to expensive. The court held three things that matter:
- Allulose is a sugar under the governing federal regulation.
- State-law consumer claims enforcing that same standard are not preempted by federal law.
- A “zero sugar” label on a product containing allulose can plausibly deceive a reasonable consumer — enough to survive a motion to dismiss.
The FDA itself filed an amicus brief at the court's invitation. Asked whether allulose is a “sugar” as defined at § 101.9(c)(6)(ii), the agency's answer was one word: yes.
That is the unusual part. The same agency that permits 0 g on the panel told a federal court the substance is chemically a sugar. Both positions are internally consistent — they answer different questions — but the combination is what plaintiffs' firms are now building cases on.
Which products this affects
Allulose shows up across the “zero sugar” aisle: protein and snack bars, Greek yogurt, ice cream, syrups, sodas, chocolate, keto baking mixes and coffee creamers. If a label leans on “0g sugar” while the ingredient list includes allulose, it fits the pattern that is currently being sued over.
The most visible example right now is the David protein bar lawsuit, filed in August 2026, which alleges the brand's “28g Protein | 150 Calories | 0g Sugar” promise is false because the bars are sweetened with allulose.
Being named in a suit is not a finding of wrongdoing, and several of these cases will lose. But if you buy this category regularly, it is worth knowing that a claim window may open years from now — see how to get notified of class action settlements.
Should this change what you eat?
Probably not, and it is worth separating the legal question from the nutritional one. Nothing in these cases alleges allulose is harmful. The FDA has treated it as generally recognised as safe, and the metabolic research is the reason it gets the panel exemption in the first place.
Two practical caveats, both well documented in the literature: allulose can cause gastrointestinal discomfort at higher doses, like most sugar alcohols and rare sugars, and it is not calorie-free — it is low-calorie. If you are counting carefully, count it.
The dispute is about what a wrapper is allowed to say, not about whether the food is good for you. Those are genuinely different arguments, and most coverage blurs them.
Glossary
- Monosaccharide
- A single-unit sugar such as glucose, fructose or allulose. The federal definition of “sugars” is the sum of free mono- and disaccharides.
- Epimer
- Two sugars with the same formula that differ in arrangement at one carbon. Allulose is an epimer of fructose.
- Nutrient content claim
- A front-of-pack statement about how much of a nutrient a food contains, regulated separately from the Nutrition Facts panel.
- Amicus brief
- A filing by a non-party — here the FDA — offering the court its view on a question of law.
- Preemption
- The doctrine that federal law can override conflicting state-law claims. The Seventh Circuit rejected it for these labeling claims.
FAQ
Neither loosely — it is a rare sugar, a true monosaccharide. Sugar alcohols like erythritol and maltitol are a different chemical class, though they are used for similar reasons.
Because FDA guidance from 2019 permits excluding allulose from the Total Sugars line on the Nutrition Facts panel. Whether that permission extends to front-of-pack marketing is what courts are now deciding.
Studies consistently show little to no effect on blood glucose or insulin, which is the basis for its panel treatment.
The FDA has treated allulose as generally recognised as safe. The main documented drawback is digestive discomfort at higher doses.
Not today. These cases are at the complaint stage. If one settles, a claim site opens and buyers get notified.
- Federal Register — FDA on declaring allulose (2019)
- FDA — guidance on the declaration of allulose
- 21 C.F.R. § 101.9 — Nutrition labeling of food
- 21 C.F.R. § 101.13 — Nutrient content claims
- 21 U.S.C. § 343 — Misbranded food
- Complaint citing the FDA amicus position (N.D. Cal.)
This article is based on public information as of Aug 25, 2026; features, prices and deadlines change. Owed is not a law firm and nothing here is legal, tax or financial advice. Corrections →
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